Bluemound Asset Management, LLC

Code of Ethics Summary

The Investment Advisers Act of 1940 imposes a fiduciary duty on Registered Investment Advisors.  Bluemound Asset Management, LLC as a portion of fulfilling its fiduciary duty to clients places each client’s interests as the paramount consideration in all decisions, actions and methods of providing services.

This document will outline both our Fiduciary Duty, as well as, our compliance with rule 201A-1 of the Act.

Our Fiduciary Duty

In recognition of the trust and confidence placed in Bluemound Asset Management, LLC by its clients, and because the Advisor believes that its operations should benefit its clients, Bluemound Asset Management, LLC has adopted the following universally applicable principles.

Clients’ interests are paramount. 

Bluemound Asset Management, LLC places client interests before their own and constantly act in the best interest of the Advisor’s clients.

The Advisor will always attempt to recognize and act in the best interest of its clients.

Further Duties

Investment Advisor Representatives of Bluemound Asset Management, LLC must accomplish all personal securities transactions in a manner that avoids a conflict of interests with its clients, in accordance with the Advisor’s Personal Trading Policy, and report personnel securities transactions at least quarterly to the Advisor.

IARs must avoid actions or activities that allow (or appear to allow) profit or benefit from your position with Bluemound Asset Management, LLC, to self, family or acquaintance, or that bring into question your independence or judgment.

IARs must comply with all applicable federal securities laws, including the prohibitions against the misuse of material nonpublic information, which includes information relating to issuers as well as to Bluemound Asset Management, LLC securities recommendations and client securities holdings and transactions, in conducting yourself and the operations of Bluemound Asset Management, LLC

IARs  must report any violations of this code of ethics promptly to your chief compliance officer and where necessary any broker-dealer as required, and where necessary to appropriate regulatory authority.

This Code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not absolve Bluemound Asset Management, LLC personnel from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients.

Specific Requirements of Access Persons (Investment Advisor Representatives and Employees and any other associate who may have access to client information) of Bluemound Asset Management, LLC

A. Prohibition Against Fraud, Deceit and Manipulation

Representatives of Bluemound Asset Management, LLC may not, in connection with the purchase or sale, directly or indirectly, of a security held or to be acquired by any client account:

1. Employ any device, scheme or artifice to defraud the client account;

2. Make to the client any untrue statement of a material fact or omit to state to the client a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading;

3. Engage in any act, practice or course of business which would operate as a fraud or deceit upon the client; or

4. Engage in any manipulative practice with respect to securities or a client.

Two of the most common risks associated with personal securities transactions are front-running and trading opposite a client account. For example, front-running would include the purchase of a security any time within seven days ahead of when a client account purchases the same security or the sale of a security any time within seven days ahead of when a client account sells the same security. An example of trading opposite a client account would include the sale of a security any time within seven days after a client account purchases the same security or the purchase of a security any time within seven days after a client account sells the same security.

B. Limits on Accepting or Receiving Gifts

In order to protect the reputation and integrity of Bluemound Asset Management, LLC access persons shall not accept any gift of more than nominal value ( totaling less than $100 over a 12month period) from any existing or prospective client, broker, persons who regulate, advise or render services to Bluemound Asset Management, LLC nor offer any such gifts.

This provision does not include:

o Occasional meals, tickets to a sporting event or the theater, or normal business entertainment, if the person or entity providing the entertainment is present; and

o Any payment or reimbursement for professional training or educational meetings.

C. Political and Charitable Contributions

Access Persons may not make political contributions for the purpose of obtaining or retaining advisory contracts with government entities relating to private pension plans or municipal securities offerings. Bluemound Asset Management, LLC will take reasonable steps to ensure that any political contributions made by it or its supervised persons are not intended to obtain or retain advisory business.

D. Confidentiality

Access Persons must keep all advisory client information confidential per the Bluemound Asset Management, LLC, Privacy Policy.

E. Interpretation of Provisions

The Executive Officer (Kirk Spano) of Bluemound Asset Management, LLC may from time to time adopt such interpretations of this Code as it deems appropriate.

F. Acknowledgment of Receipt and Annual Certification

Each IAR will receive a copy of this Code and any subsequent amendments to the Code, and must acknowledge receipt of the Code in writing. In addition, each person is required to certify annually that he/she (i) has read and understands the Code, (ii) is aware that he/she is subject to the provisions of this Code, (iii) has complied with the Code at all times during the previous calendar year, and (iv) has, during the previous calendar year, reported all holdings and transactions that he/she is required to report pursuant to the Code.